This firm represents BioForce Nanosciences Holdings,
Inc. ("BioForce" or the "Company" or the "Registrant"), which filed
its Registration Statement on Form 10 on December 19, 2017.
Your office recently provided comments to the above
referenced filing in your letter dated January 11, 2018 ("Comment
Letter"). At this time, we are submitting, on behalf of
BioForce, this letter in response to your Comment Letter and we are
providing responses keyed to the paragraphs in the Comment Letter.

Accordingly, our responses to your Comment Letter
are as follows:

Business, page 3

1.

The Company was previously the business of
manufacturing nano-particular measurement devices and molecular
printers. Due to a lack of profitability, management decided
to abandon that business on or about March, 2013. At that
time, the Company had no assets related to its previous business
model. New management came into the Company in or about April, 2013
and planned to focus on a new business model in the food services
sector, production or agricultural facilities within the food
service sector. That is the import of the January 3, 2017
press release. The first paragraph under the heading
"Business" has been revised to include this information.

2.

The press release dated October 18, 2017 reflected
work the Company was doing in an attempt to move its business to a
more successful and eventually profitable business model as
discussed in paragraph 1 above. The Company's October 18, 2017
press release did not mention any specific acquisitions. That
press release reflects the fact that the Company was looking at a
number of businesses operations for possible acquisition. Due
diligence continued on these potential
acquisitions and management believed at least one or more could
have been acquired potential. Ultimately, however, management
decided not to acquire these businesses, instead it entered into
the business of producing and marketing vitamins and nutritional
supplements in December, 2014. We do not believe it would be
appropriate to describe the process of the search for a new
business model in the Registration Statement, because we would just
be describing the methodology as to how we got to where we are.
This would provide no material information about the current status
of the business of the Company, which is the information that would
be material to investors.

United States Securities and Exchange Commission

January 26, 2018

Page 2

3.

The Company believes that its BioForce Eclipse
nutritional powder is unique, because no one else offers the
product under that name. However, the term "unique product
offering" has been removed as nonessential. Management
believes its proprietary products are less expensive than
comparable products of its competitors, and they believe that the
product has better more efficient results. The reference to
the goal of assuming that the product meets certain standards
refers to the quality of the formulation and the presentation of
the product.

4.

The disclosure required by Regulation SK Item
101(h)(4)(xii) regarding a description of the number of total
employees and the number of full time employees has been included
on page 5, just above the heading "Reports to Security
Holders."

5.

The manufacturer of BioForce Eclipse, owns the
rights to the formula for the product. The Company has an
agreement with the manufacturer that gives the Company nonexclusive
rights to market the product. The Company owns the right to
the product name, "BioForce Eclipse". A revised disclosure on
page 4 clarifies this position.

6.

The FDA does not have to clear the Company's
products for sale in the United States. However, as with any
food items, the FDA does have rules regarding food available for
public consumption. These rules would apply the Company's product
as well as any other type of food product. This information
is disclosed in a new paragraph 4 page 4.

7.

We have included a new paragraph on page 5 that
addresses the issue of one customer, and we have included a new
risk factor that discusses the one customer situation.

We cannot assure you that there will be an active
trade market, page 10

8.

General vernacular refers to stock sold on the OTC
Markets as stocks sold on the bulletin board. In order to be
more precise and specific, we have changed the reference on page 10
to state that the Company's stock is traded on the OTC Markets,
Inc. with a current information designation.

It may be difficult for a third party to acquire
us, page 10

9.

The last bullet point of this risk factor has been
eliminated.

Nine Months - September 30, 2017 and 2016
Statements, page 15

United States Securities and Exchange Commission

January 26, 2018

Page 3

10.

The Company's change in revenue and change in gross
margins for the periods presented in the financial statements are
due to the fact that orders for the Company's product fluctuated.
The decrease in cost of goods sold for the nine months ended
September 30, 2017 compared to the nine months ended September
30, 2016 was due to a reduction in product sales. Gross Profit
for the nine months ended September 30, 2017 was $-0- as compared
to gross profit of $1,500 for the nine months ended September 30,
2016. The decrease in gross profit for the nine months
ended September 30, 2017 compared to the nine months ended
September 30, 2016 was due to a reduction in sales.

Properties, page 17

11.

The Company is primarily a sales organization;
therefore, it does not need much property to operate. It
shares office space with Yes International at no cost.
Yes International is owned and operated by the
Company's Secretary and Director, Richard Kaiser.

We believe that the shell definition does not apply
to BioForce, because the definition of a shell company was never
intended to apply to an operating company such as BioForce, which
is simply in the process of changing its business plans. As
noted previously, the Company was previously in the business of
manufacturing nano-particular measurement devices and molecular
printers, and the management of the Company in March, 2013 decided
to abandon that business. Subsequently, a new management came
in and pursued a new and different business plan. They are
now in the process of pursuing this Company's new business
model.

We believe that the definition of the term "shell"
does not apply to BioForce, because the definition of a shell
company was never intended to apply to an operating company such as
BioForce, which is simply a company in transition from one business
plan to another business plan. Otherwise, all companies that
transition from one business to another would become shells, and
that result was never intended and would be contrary to the
regulatory scheme. This is made clear in the SEC's adopting
release for Rule 144, Adopting Release No. 33-8869 footnote 172,
which states "Rule 144(i)(1)(i) is not intended to capture a
startup company or in other words a company with limited operating
history in the definition of a reporting or non reporting shell
company as we believe that such a company does not meet the
condition of having no or nominal operations." This footnote
applies to the BioForce situation as well, because it was an
operating company before the change of business, and it continues
to be an operating company after the change of business.

The Company has been in business continuously since
the time it was formed in December, 1999. As stated above,
BioForce has operated as a sales organization and as such it is not
necessary for it to carry a lot of assets, and its revenues are
low, because of the fact that it is in the start-up phase of its
new business. For these reasons, we believe that BioForce
does not have "no or nominal operations" in the sense described in
the SEC Release No. 33-8587 or in the sense described in Rule
144(i), and therefore it is not a shell.

United States Securities and Exchange Commission

January 26, 2018

Page 4

Directors and Executors Officers, page 17

12.

Mr. Ferguson and Mr. Kaiser became officers and
directors on or about July 8, 2013. Mr. Ferguson had no previous
relationship with the Registrant prior to joining BioForce as an
officer. Mr. Kaiser did have a prior relationship with the
Registrant, in his position as owner and operator of Yes
International, Inc., which provided Edgar filing services and
public relations services for the Company.

Biography, page 18

13.

Mr. Ferguson's biography refers to Predictive
Technology Group and Element Global, Inc., as public companies.
They were referred to as public companies, because their
stock is publicly traded. We have revised the disclosure to
reflect that the stock of these companies is publicly traded and
describing the market on which the stock is traded. Moreover,
Predictive Technology Group and Element Global, Inc. are not
related to BioForce, and delinquent filings of those companies have
no impact on the status of BioForce's compliance obligations, and
we believe there is no risk factor associated with this issue.

14.

The biographies have been revised to provide the
disclosures required by the last sentence of Regulation SK Item
401(e)(1) relating to the level of professional competence for each
director.

15.

The disclosure under Item 5 Directors and Executive
Officers has been revised to include the information required by
Regulation SK Item 401(e)(2) regarding directorships held by the
directors in the past five (5) years. This includes the
disclosure of Mr. Kaiser's position with Bravo Multinational,
Inc.

Executive Compensation, page 18

16.

The disclosure under the heading Employment
Contract" has been revised to reflect the employment contract
between the Company and Mr. Ferguson for the period from July 1,
2013 through June 30, 2018. That contract will also be filed
as an Exhibit to the Registration Statement pursuant to Regulation
SK Item 601(b) (10).

Certain Relationships and Related Transactions,
page 19

17.

The only related party transactions involve
transfers of stock to the directors of the Company, and this
information is disclosed under Item 6 Executive Compensation.
The reference to the issuance of common stock in the
statement of cash flows on page 26 of the financial statements
describes the cancellation of certain advances made by the
directors of the Company in exchange for stock issued to the
directors. We don't believe that the issuance of shares to
directors is a required disclosure under Section 404 Regulation SK.

Shares Eligible for Future Sale, page 21

United States Securities and Exchange Commission

January 26, 2018

Page 5

18.

At this time, the Company has 66,347,740 shares of common stock eligible for resale
pursuant to Rule 144.

Signatures, page 37

19.

Registrant's name has now been included on the
signature page as required by Form 10.

Exhibits.

20.

The Supplier Agreement between the Company and Body
Align, LLC, which contains the consignment terms mentioned on page
4 has been filed as an exhibit to the Registration Statement
pursuant to Regulation SK Item 601(b)(10).

We trust the comments contained herein are
responsive to the issues raised in the Comment Letter. We are
simultaneously filing a revised Form 10, and we are filing as
correspondence a copy of this response to your Comment Letter, as
well as redline copies of the Form 10, which has been marked to
show changes from the original filing.

If you have any questions on these responses or if
you need additional clarification of the issues discussed, please
contact me at the telephone number noted above.